- 65 - On the Schedule L attached to PKVI LP’s Form 1065 for 1990, no amount “DUE TO AFFILIATED COMPANIES” was listed under “Other liabilities” as of the end of that year. On its Form 1065 for 1991, PKVI LP reported imputed interest payments totaling $100,661. There were no amounts separately identified as interest payments made and/or imputed by PKVI LP to PK Ventures, TBPC, or TPTC on its Form 1065 for 1991. PKV&S claimed a bad debt expense of $1,712,151 on its audited consolidated financial statements for the year ended December 31, 1991. Of this amount, $1,312,151 was attributable to the transfers that PK Ventures had made to PKVI LP in 1991 and prior years. Note 3 to these financial statements offered the following explanation for PKV&S’ claiming a bad debt expense with respect to these transfers: At December 31, 1990, the Company had made $1,096,250 of noninterest-bearing advances to PK Ventures I Limited Partnership (LTD) in which it has a 1% general partnership interest and a 29% limited partnership interest. The Company made additional advances to LTD in 1991 of $419,996, principally to fund operating losses. Management of the Company believes that recovery of its advances to and investment in LTD is unlikely and, accordingly, has forgiven advances amounting to $1,312,151 in 1991 and charged bad debts expense. The Company also recorded losses under the equity method of $129,095 in 1991 and $75,000 in 1990. PKV&S claimed a $1,916,246 bad debt deduction on its consolidated income tax return for 1991 for the cash transfers that PK Ventures, TBPC, and TPTC had made to PKVI LP and for the cash transfer that PK Ventures had made to Rose in connectionPage: Previous 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 Next
Last modified: May 25, 2011